Extract to table

1018-00009 — must read this memorandum in its entirety and acknowledge their understanding of, and agreement to comply with, these protocols

This distinction is critical: while C&H may receive documents from, and coordinate with, PPC affiliates in connection with the defense, the privilege protections discussed in this memorandum apply to communications between C&H and PPC, not to communications between C&H and PPC's affiliates (except to the extent that affiliate employees are acting as agents of PPC for purposes of the privileged communication, a determination that must be made on a case-by-case basis by Cross or Hartwell)

Paralegals and support staff assigned to the matter must be briefed on these protocols before beginning any work on the matter

Each occupies a distinct position with respect to privilege protections, and the team must understand and observe the differences carefully

Several fundamental principles must be borne in mind: The privilege belongs to the client

The team must be vigilant in preventing inadvertent waiver